Form 8606

Taxpayer made a non-deductible IRA contribution in 2009. Did not file form 8606. 10 years later, made another nondeductible contribution for 2019 and did not report on form 8606. We picked up this taxpayer as a new client for 2020. We plan to file an amended 2019 form 8606 to report the correct after-tax basis for the 2019 contribution and would like to also pick up the 2009 contribution. Question: should we file an amended 2009 return and report the form 8606 or just report the carryover basis on the 2019 form without filing 2009 and move on? Or are we barred due to SOL from picking up this basis from 2009 since so old and never filed.



The IRS has been accepting retroactive 8606 forms without age limit, but taxpayer should be sure a TIRA contribution was made in 2009 that was not deducted before sending in the 8606. These forms can be filed without amending a return so can be sent in together with a brief note. The 2009 form is needed and that basis cannot be added to 2019 without filing the 8606 for 2009. Also, if there has been any distributions in the last 3 years, those returns do need to be amended to reflect the correct taxable amount based on the additional 2009 basis.

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